Opinion Statement on the OECD Inclusive Framework BEPS Package Stocktake Exercise
CFE Opinion Statement 1/2025
CFE Tax Advisers Europe has published an opinion sttement in response to the OECD Inclusive Framework’s BEPS Package Stocktake, calling for simplification, proportionality, and balanced implementation to sustain competitiveness and fairness in international taxation.
Executive Summary
- BEPS has significantly aligned profits with real economic activity, enhancing transparency through CbCR, DAC exchanges, and treaty anti-abuse measures.
- The EU strengthened global implementation efforts, by adopting BEPS Actions via ATAD 1 & 2 and DAC 1-6, but this implementation has created significant complexity and compliance burdens for businesses.
- Complex anti-avoidance and reporting rules, such as hybrid mismatch provisions and DAC6 hallmarks, have increased compliance costs, created uncertainty, and risk undermining competitiveness without proportional benefits.
- CFE calls for simplification, consolidation of overlapping EU frameworks (e.g. a unified DAC), clearer guidance on rules such as hybrids and interest limitation, and balanced anti-abuse measures that do not penalise genuine business arrangements.
- Improved dispute resolution remains essential, with CFE supporting the EU’s binding arbitration approach under Action 14 while calling for further enhancements to reduce double taxation risks globally.
